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Podcast: Offshore Tax with HTJ.tax
Episode: CRS Commentary on Financial Institutions Holding Equity Interests
Description: This episode examines a pivotal provision in the CRS Commentary—paragraph 178 (Section VIII, C(4))—and its implications for trusts that qualify as Reporting Financial Institutions (FI-trusts).The key issue: When equity interests in an FI are held through a Custodial Institution, who reports?📘 The CRS Commentary (p. 178, C(4) – Equity Interest)Under the Commentary issued by the Organisation for Economic Co-operation and Development, paragraph 69 clarifies that:In the case of a trust that is a Financial Institution, an “Equity Interest” is considered to be held by any person treated as a settlor or be...